Case 1:01-cv-00669-FMA
Document 105
Filed 08/28/2007
Page 1 of 2
UNITED STATES OF AMERICA COURT OF FEDERAL CLAIMS BENJAMIN ALLI, SHAKI ALLI and BSA CORPORATION, a Michigan Corporation Plaintiffs, vs. UNITED STATES OF AMERICA, Defendant. _____________________________________/ STEMPIEN & STEMPIEN, PLLC By: Gregory J. Stempien Eric Stempien Attorney for Plaintiff 315 N. Center Street, Suite 200 Northville, MI 48167 (248) 735-9200 DEPARTMENT OF JUSTICE, COMMERCIAL LITIGATION By: Marla Conneely Attorney for Defendant 1100 L Street N.W., Room 11054 Washington, DC 20005 (202) 307-0318 _____________________________________/ PLAINTIFFS' UNOPPOSED MOTION TO EXTEND DEADLINE FOR FILING OF POSTTRIAL BRIEFS Plaintiffs, by and through their attorneys, hereby move this Honorable Court to enter an order extending the deadline for the filing of the parties' post-trial briefs and in support thereof rely on the attached brief. Case No. 01-669C Judge Allegra
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Case 1:01-cv-00669-FMA
Document 105
Filed 08/28/2007
Page 2 of 2
BRIEF IN SUPPORT OF MOTION Plaintiffs request a short extension of the deadlines for filings of the post-trial briefs. Plaintiffs' request is that the initial briefs be filed simultaneously on October 5, 2007 and that the responses be filed simultaneously on November 27, 2007. Plaintiffs' counsel's partner has scheduled a vacation for the week of September 24, 2007, the week before the deadline for the filing of the initial briefs in this matter. Plaintiffs' counsel is a member of a two attorney law firm. When one partner is scheduled to be out of the office, the other partner must be available to cover the other's files for that week. This is especially true for the week of September 24, 2007 because Plaintiff's counsel's partner is scheduled to be out of the country. Therefore, it will be very difficult to be able to complete the initial post-trial brief during that week. Also, Plaintiff's counsel received notice last week for a jury trial on November 13, 2007. The trial is expected to last four to five days. The staff for the presiding Judge in that matter confirmed that the trial will begin on November 13, 2007 because this is the only matter scheduled for that day. Plaintiffs request an eight day extension of the deadline to file the responses t to allow time for preparation of the response. Defense counsel concurs with the relief requested in this motion.
STEMPIEN & STEMPIEN, PLLC
s/Eric Stempien______________ By: Eric Stempien Attorney for Plaintiff 315 N. Center St, Ste. 200 Northville, MI 48167 [email protected] Dated: August 28, 2007
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